The Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Final Rule CANNOT be implemented prior to the current effective date of September 30, 2009. Also, existing tenants and applicants are encouraged to start the process of applying for a Social Security Number (SSN) if they do not already have them. The majority of current tenants without SSNs are under the age of six.
http://edocket.access.gpo.gov/2009/pdf/E9-1248.pdf